Recruitment Agents - New Responsibilities for Student Sponsors

Since 7 April 2026, student sponsors have new responsibilities in respect of the agents and third parties they use to recruit their sponsored students. This includes a new mandatory duty to insert agent details when assigning a Confirmation of Acceptance of Studies (CAS) to a prospective sponsored student.

The role of recruitment agents in the potential abuse of the sponsored study visa routes was first raised in May 2024 by the Migration Advisory Committee (MAC) when it conducted a review of the Graduate Visa Route. As part of this review, the MAC recommended greater regulation of international student recruitment agents to reduce poor and misleading agent practices.

The Immigration White Paper published last May then saw the Government proposing a new requirement for all student sponsors using recruitment agents to sign up to the Agent Quality Framework (AQF). The AQF is a sector led initiative with best practice and quality assurance standards in the management of international student recruitment agents.

Updated student sponsor guidance outlining new responsibilities regarding recruitment agents was formally published on 7 April 2026 (Updated Guidance). In March 2026, the UKVI’s Study Services team had previously shared with student sponsors an FAQ document on CAS Changes providing further clarification on the new requirement to insert agent details on a CAS (FAQ Document).

New record keeping and reporting duties relating to recruitment agents contained in the Updated Guidance and FAQ Document, together with a new requirement for student sponsors to commit to AQF principles, signals a clear message from the UKVI that student sponsors cannot outsource their responsibility to recruit international students. We have outlined the key new duties and responsibilities on student sponsors below.

New Agent List Requirement

Under existing sponsor duties, student sponsors have been required to provide UK Visas and Immigration (UKVI) with details of any third parties, in the UK or another country, used to recruit students.

According to the Updated Guidance, this existing duty has been expanded to require current student sponsors to provide a list of all agents or third parties – in the UK or another country - used to recruit international students (Agent List). In addition, sponsors must thereafter update the UKVI of any additions to or removals from their Agent List within 20 working days of becoming aware of the change.

There is also a new requirement for an education institution applying for a student sponsor licence for the first time to provide a list of all agents or third parties (both in the UK or another country) that they have used or intend to use to recruit and sponsor international students.

The information that must be provided about agents or third parties to the UKVI is set out in the SMS Guide 4A - Creating a CAS - guide for sponsors and is as follows:

• Agent Company Name: This must be the company’s formal legal name used in the contract with no acronyms/abbreviations
• Agent Contact Name: This must be the name of the primary agent contact for that contract, including their family name
• Agent Contact Address: This should include the first line of the address including building name/number, street, city/town, postcode/zip code (where used), and the country. Where the agent information must be provided on the CAS for the specific sponsored student, as per the new CAS Agent requirement set out below, this address should be the address for the specific branch of the agent from which the student was recruited.

In order to bring all student sponsors in line with this new Agent List requirement, the UKVI are contacting all existing student sponsors to request submission of their list of current recruitment agents and third parties.

New UKVI Reporting Requirement re Changes to Agent List

The Updated Guidance also sets out the circumstances when a change in a student sponsor’s Agent List must be reported to the UKVI and how:

• Sponsors must provide to the UKVI details of any agents or third parties that have been added to, or removed from the list which they provided in response to the UKVI’s request to provide an Agent List (or from the list originally submitted with their sponsor licence application). The UKVI have also published a guide called “How to complete the UKVI Agent and Third Party Disclosure Form”. This confirms that sponsors must also report where there are changes to agent details including change of agent name, contact name or address.
• Sponsors must inform the UKVI by using the following email address: Studythirdpartydisclosure@homeoffice.gov.uk within 20 working days of becoming aware of the change.
• Where a new Agent needs to be reported to the UKVI, the details required are as set out in the agents section of the SMS Guide 4A - Creating a CAS - guide for sponsors.

The Updated Guidance also confirms that where an agent for a particular student subsequently changes after their CAS is assigned, sponsors do not need to report this change of agent to the UKVI.

Moreover, rather than a student sponsor needing to report Agent List changes via an online Sponsor Management System (SMS) report, it will be necessary to send an email to the specified email address via an offline process. It will therefore be important for student sponsors to keep a record of these reporting emails in a centrally accessible location in the event of a UKVI Compliance Visit in order to demonstrate compliance with this new Agent List Changes reporting duty.

New CAS Requirement to Insert Agent Details

In addition to the new Agent List and Agent List Changes Reporting requirements, student sponsors must now include agent details on the CAS where a sponsor has used an agent or a third party in the recruitment of that sponsored student. This new mandatory duty to insert agent details on the CAS applies to all CAS assigned on or after 7 April 2026. Prior to 7 April 2026, completion of the agent fields on the CAS had been optional since these fields were first introduced by the UKVI in June 2025.

The details about agents that must be inserted on the CAS are those set out in the SMS Guide 4A - Creating a CAS - guide for sponsors (and the same as set out above in relation to the new Agent List requirement). Sponsors can use a ‘Sponsor Note’ on the CAS to amend any minor errors in the agent fields after a CAS is assigned. However, the Updated Guidance confirms there is no duty to report to the UKVI if an agent subsequently changes after the CAS has been assigned.

When does the requirement to insert Agent Details on the CAS apply?

• The Updated Guidance makes clear that sponsors must provide agent details on the CAS in any instance where the sponsor has used an agent or third party in the recruitment of that student.
• The Updated Guidance states that the agent details inserted on the CAS should reflect the agent used by the sponsor during the ‘recruitment phase’ and who the sponsor “attributes the recruitment of that sponsored student to”. An example given in the Updated Guidance is the agent who will receive any commission payment should be included on the CAS. The FAQ Document also confirms “The agent details should reflect the agent that is contracted to the sponsor, and they have (or will be) paid commission for recruiting that student.”
• The FAQ Document confirms that a ‘third party organisation’ is defined as “an organisation or individual contracted to the provider and is paid commission as part of the recruitment of that student.”
• The Updated Guidance states the requirement to provide agent details on the CAS applies even where this was a “one off recruitment and/or the recruitment was done without a formal ongoing contract with the agent or third party”. Where a sub agent is used, the Updated Guidance confirms that details of the main agent must be inserted on the CAS, rather than the sub agent.

When Are Agent Details Not Required on CAS?

• Where an agent or third party was not used by the student sponsor as part of the recruitment process, no agent details need to be inserted on the CAS. The Updated Guidance confirms that this includes where an agent has been engaged directly by the student to provide support with their application, but that third party was not used by the student sponsor in the recruitment process. The FAQ Document confirms the “UKVI are interested in agents that are used in the recruitment of that student, not post application support.”
• The FAQ Document also makes clear that agent details are not required to be inserted on CAS for continuing students extending on the same course or who are progressing from a pathway, Further Education college or independent school that has a partnership with a university.

New Commitment to the Agent Quality Framework Requirement

The Updated Guidance also introduced a new requirement that all student sponsors using recruitment agents must have committed to adhering to the key principles of The UK Agent Quality Framework The Updated Guidance notes “As part of these commitments, sponsors may want to consider the recommended actions and best practices as set out on the AQF web page.”

The Updated Guidance states that all student sponsors using recruitment agents must “retain evidence of how they are managing agents in line with the AQF and The National Code of Ethical Practice for UK Education Agent as applicable to the school, further education, pathway and higher education sectors.”

Neither the Updated Guidance nor the FAQ document gives any detail about what AQF evidence UKVI Compliance Officers would expect to see on a UKVI Compliance Visit. However, such evidence could include template agent due diligence questionnaires, Recruitment Agent policy, signed agent contracts (with associated references received), training/induction provided to contracted agent and/or British Council Training certificates from the contracted agent.

Use of Agent Data and Implications on Student and Child Student Visa Applications

The FAQ Document confirms that the UKVI policy intention behind this new Agent CAS requirement is to use the data collected to understand how agents are used by student sponsors, further noting “the information will support the analysis and identification of trends, in particular where there may be an association with repeated adverse outcomes (for example, the use of fraudulent documents).”

The FAQ Document also raises the possibility that the UKVI may consider publishing in the future grant/refusal rates associated with agents, similar to the process currently operated in New Zealand.

The FAQ Document provides reassurance that the insertion of an agent or third parties details on the CAS will not determine the outcome of the Child Student or Student visa application as applications will continue to be assessed in line with the Immigration Rules. The FAQ Document does state, however, that if any evidence provided in an application provides ‘reasonable cause for concern’ the UKVI reserves the right to undertake additional checks.

Action for Student Sponsors

It is clear that sponsors must now take measures to introduce responsible recruitment practices into their sponsor compliance processes and to remain compliant with their sponsor duties. In particular, student sponsors should ensure that they:

• Maintain an accurate and up to date record of all contracted education agents and third parties used to recruit and enrol international sponsored students
• Incorporate changes to your list of recruitment agents (additions/removals/changes to agent details) into your UKVI reporting duties processes
• Keep a careful record of the source of a sponsored student’s recruitment - for instance, whether the individual is a direct applicant, from an independent school, pathway provider, employer or recruited via a recruitment agent or third party
• Where a sponsor attributes that prospective sponsored student’s recruitment to an agent or third party, their details must be inserted on any CAS assigned on or after 7 April 2026
• Use the AQF’s Good Practice Guide for Providers Using Education Agents to assess how your institution can demonstrate adherence to AQF principles when managing your agents, as applicable to your institution’s profile, size and resources.
• All processes relating to the management of education agents should be documented and held in a centrally accessible electronic folder – which can be shown to the UKVI upon request.

We can assist with updating your processes to comply with the new sponsor duties relating to the use of Recruitment Agents or answer any queries about how your institution can demonstrate commitment to the key principles of the Agent Quality Framework.